Keywords: inspection; nuclear material control and accountancy (NMC&A); quality management system

Transcription

1 French Domestic Safeguards inspections with regard to quality management system of the operators, in the field of nuclear material control and accountancy Julie LASNEL-PAYAN, Flavien LEMOINE, Bruno AUTRUSSON, Eric GOSSET Institut de Radioprotection et de Sûreté Nucléaire B.P Saint Paul-lez-Durance Cedex - France [email protected], [email protected], [email protected], [email protected] Abstract: The French code of Defence states that the operators must follow-up the nuclear materials in their facilities and have to implement the technical conditions for nuclear material control and accountancy (NMC&A) under a quality management system which complies with the relevant international standards. This quality management system shall concern particularly: receipts and shipments of nuclear materials, recognition of nuclear materials through checking and testing with a special attention on the related measurements, physical inventory taking of nuclear materials. These provisions lead French Domestic Safeguards to include operator s quality management system in the NMC&A verification program. The French safeguards inspection focuses particularly on movements and transformations of nuclear material, measuring and testing equipment, accountancy as well as identification and traceability, audits, nonconformities and defects management in the scope of NMC&A. This control is based on procedures contents and application, but above all on the associated document in proof. Such inspections are a good method to assess the efficiency of interfaces between the nuclear material management, the operator accounting system and the national accounting system. This paper describes the verifications that are made by formal inspectors from French Domestic Safeguards and the lesson learnt. As a matter of fact, such controls provide wider information on the management of nuclear material in facilities over time and not only an overview of the inspection setting. Keywords: inspection; nuclear material control and accountancy (NMC&A); quality management system 1. Introduction In France, the protection and control of nuclear materials is based on the code of defence which has been published in december Concerning nuclear material control and accountancy (NMC&A), the technical conditions are set by the order of 16 March In the first article it is written that the operator shall implement a quality management system which complies with the relevant international standards, to day it means ISO In the field of material control and accountancy the operator shall implement a quality management system concerning particularly: receipts and shipments of nuclear materials, checking and testing with a special attention on the related measurements, 1

2 physical inventory taking of nuclear materials. The aim of this paper is to present the verifications made by the inspectors of the French National Safeguards to ensure that these measures are correctly applied. 2. Inspections with regard to quality management 2.1 Inspection s team and scope The team of French National Safeguards inspectors (most of them coming from IRSN which acts as the technical support body of the Authority), includes generalists inspectors and specialized inspectors in measurements or accountancy. Furthermore some inspectors are trained to perform internal audits in IRSN and it is an interesting skill for inspections with regard to quality management. In France the licensing is based on an authorization file, which described all the organization and provisions implemented by the operator to protect and control the NM. The preparation of the inspection is made with the help of the authorization file of the operator. All the others documents such as procedures or operating instructions can be seen during the inspection. The reference documents of the inspection is mainly the order of 16 march The scope of the inspection is: general organization and responsabilities, review of the reference state of the facility, identification and traceability, control of nuclear material, accountancy, recording and storage, interfaces (mainly between control and accountancy), control of measuring and test equipment, internal verification and audit, measure, analysis and improvement. All these items concerning the nuclear material management are reviewed taking into account the requirements of the ISO standard. The French National Safeguards control that quality management system and the rules implemented in organization and management which contribute to the quality of nuclear materials control and accountancy are established, implemented and maintained in order to improve the efficiency of this system. The areas covered are, at least, those mentioned in the order of 16 March 2004 (see Section 1) which, in practice, means that all activities related to nuclear materials control and accountancy, as well as their verification, shall be included in the quality system. Following those inspections, the operators are required to inform the regulatory body (the High Civil Servant for Defence at the Ministry for Industry) of the progress of these actions. 2.2 General organization and responsabilities The national safeguards inspectors control that the specific organizational system set up for nuclear material control and accountancy is defined and described in the specific documents. In particular, the 2

3 main participants shall be expressly designated and their tasks shall be set out in the same way. The main participants are: the facility director, authorized to hold nuclear materials. In the event of a single company being present on several sites (i.e. COGEMA, EDF, CEA), the facility director is not the authorization holder (usually, it is the company manager) but the "appointed representative for the facility" of the company, the person appointed as the custodian of the nuclear materials by the facility director. This person is subject to legal obligations under the code of the defence (informing the authorities if any nuclear materials are assumed to be missing), staff members responsible for the control of nuclear materials, staff members responsible for nuclear materials accounting. All these persons shall be qualified, having received suitable basic training, advanced training and/or have recognised experience. The national safeguards inspectors may check relevant documents related to training received. 2.3 Review of the reference state of the facility In this part of the inspection the reference state of the facility should be reviewed; it consists in the documents submitted to the regulatory body for the licensing process which are mainly: the initial licensing and control file associated to the initial request for licence, all the modifications to this initial file (change of authorized quantities of nuclear material, new activities ), provisions adopted for NMC&A, protocols established with others licensees for the shipments and receipts of nuclear material, documents designating the licence holder and his appointed representative for the facility. The role of the national safeguards inspectors is to verify that all these documents are maintained up to date but not to analyse them. The analysis of documents is another process. 2.4 Identification and traceability A quality system applied to the control of nuclear materials implies that they shall be identified in a consistent way, throughout their life in the facility. An identification system shall include a single content reference as well as a record sheet indicating at least the identity, the quality and the quantity of the nuclear materials. The sheet shall be affixed to the contents or in their immediate vicinity in the event of practical difficulties (glove boxes, shielded cells, size of contents) or for confidentiality requirements. All data related to the nuclear materials records in the facility shall be maintained, in the form of documents. In these documents, what is concerned, who and when shall be specified. Regarding the sensibility of the NM, those documents are managed under specific confidentiality rules. It is particularly important that traceability be exhaustive, that is to say that all the interim storage, transformation and reprocessing phases be taken into account, from delivery to shipment of the nuclear materials in the facility. Likewise, it is essential that all the materials held be rigorously 3

4 controlled, including discards and waste, and not only those which constitute the main throughput of the facility. It should be noticed that the identification and traceability of nuclear materials is rarely based directly on the materials themselves but more often on items in which they are incorporated (rods, fuel subassemblies and various set-ups) or on the different contents, in particular in the case of gases, liquids, powders, or waste. All modifications to the processing of nuclear materials shall therefore be carefully controlled. The national safeguards inspectors control that these requirements have been properly met. 2.5 Control of nuclear materials All the movements and transformations of nuclear materials have to be accompanied by documents at each workstation in the facility, validated and transmitted to the centralized control system. The French Safeguards Inspectors shall control the corresponding procedures and operating instruction, their application and the global traceability. The licensee has the legal obligation to know at all times the quantities and qualities, the locations, uses, movements and transformations of nuclear materials in his facility;the effectiveness of the implemented system to attain this objective shall be demonstrated. The licensee shall also describe in procedures the check and testing of nuclear materials at delivery and, in particular the measurements related. These operations take place in two stages: in the 24 hours following the arrival of the nuclear materials the first level of control with fast non destructives assays (item counting, labels checking..) later on (but within the year following the arrival of the materials) the second level of control that determines accurately the quantities of nuclear materials is realized. When it is not possible, audits shall be performed by the licensee in the shipper organization. In this case, associated audit reports can be controlled by the inspectors. Generally speaking, these reports contain a lot of information and highlight any dysfunction that may have occured between shipper and receiver. All the discrepancies shall be treated in coordination with the shipper and transmitted to the national accountancy system. Furthermore, the safeguards inspectors control with a particular attention the drawing up materials balances (material unaccounted for) and the calculation of their range of confidence as well. Within the frame of control of NM, the licensee has the regulatory obligation to ensure that the assumed empty containers are realy empty (vacuity procedure). The inspectors should control the associated documentary evidences. 2.6 Accountancy of nuclear materials The implemented system of accountancy of the licensee shall maintain up to date the documents governing nuclear materials accountancy (such as the book inventory of the plant, the bookeeping record of the movements) and allow the transmission in time of validated accounting declarations to the National Accountancy system (kept by the Institute for Radiation Protection and Nuclear Safety). The national safeguards inspectors make sure that these documents do exist and are applied adequately. 4

5 All the operating instructions related to «specific events» are examined such as inventory differences, material unaccounted for, disposal of N.M, accidental loss, shipper receiver discrepancy, etc. 2.7 Recording and storage A particular attention should be devoted to the verification of recordings. The document storage rules shall also be described. The French regulation for NMC&A details the prescriptions of storage:most of the documents shall be retained in the facilities for 5 years after the nuclear materials concerned have leaved the site (for accountancy documents and their technical justification documents), some other shall be retained 5 years after a certified vacuity of the facility (detailed inventory report and their technical justification documents, bookkeeping records and documents giving evidence of the results of the associated recolements). 2.8 Interfaces An important item that inspectors could check is interfaces and descriptions of them. It includes particularly interfaces between physical control and accountancy, but also between local accounting system and National Accountancy system, as well as shipper and receiver of nuclear materials (cf. 2.5 and 2.6). 2.9 Control of measuring and test equipment In order to control the NM, measuring devices are implemented, in relations with their form. The equipment concerned are those which are associated with the control of nuclear materials (weighing machines, on line measuring devices, analysis devices, computerized data processing systems, etc.). The objective of this control is to identify and put aside equipment which neither comply with specified requirements, nor with the associated methods. During their inspections, the national safeguards inspectors can control, totally or partially, the following points (non-exhaustive list): that measuring systems and methods are described, that a measuring programme exists, detailing by type of measurement, the frequency and the accuracy required, how consistent sampling is, the frequency of calibration and the availability of corresponding reports, calibration certificates of the standards used, the protection of test equipment against possible adjustments which would invalidate calibration setting Internal verifications and audits Internal verifications are performed by the operator himself in order to control that provisions related in the differents NMC&A documents are effective and correctly managed. These verifications consist of (non-exhaustive list): 5

6 periodical physical inventories of nuclear materials, by sampling from inventory lists, counting, performing measurements and checking the presence and location of items, with regards to the control files. These periodical inventories are different from annual inventory required by regulation for each licensee, at least once a year, randomly verifications of the effective implementation of regulations, control of coherence between the book inventories in the local accounting records and the physical inventory as well as book inventories in the local accounting records and those in the centralized accounting system. Besides, each licensee of nuclear materials shall be subjected to internal quality audits, organized by the management. The aim is to check the efficiency of the quality system implemented for nuclear material control and accounting. During their inspections, the national safeguards inspectors generally check thoroughly the list of planned audits in the scope of NMC&A as well as the audit reports and corrective actions decided upon following these audits Measure, analysis and improvement The approach for dealing with nonconformities and defects shall include research into their causes and shall call for corrective actions if necessary. The nonconformity and defect reports as well as the corrective action lists drawn up shall be maintained and may be assessed by national safeguards inspectors. However, it s worth noticing that corrective actions are requested, if needed, following inspections by national safeguards inspectors. These is systematically controlled by the national safeguards inspectors. In order to evaluate the opportunity of improvement for the processes concerned, management reviews (formal evaluation, by the management, of the status and adequacy of the quality system in relation to quality policy) shall be organized. Inspectors could check that quality management reviews are performed at regular intervals. In fact, the improvement of quality management system in the scope of NMC&A is directly or indirectly linked to the experience feedback ie lessons learnt from problems that have already occurred in the facility or in other facilities (from the same company for example). 3 Conclusion The wants in tracability, responsabilities, recording, archiving, to attain the objectives as well as the continual improvement introduced into the quality system reach the expected aim so as to get an efficient NMC&A system. Their introduction in the NMC&A regulation provides to the operator a framework to control NM (a framework that the operator uses in order to manage the quality management system). It allows the inspector to point out the recorded history of the items, the process at work and also to determinate any responsability in case of dysfunction. So, this is all to keep in 6

7 mind, that the aim of the inspection mission go further than quality audits and allow to control that the dispositions implemented by the operator guarantee the protection and control of NM. The lessons learnt from documentary evidences assessment, from internal verifications and audits as well as measure, analysis and improvements are particularly significant. Indeed, such controls provide wider information on the management of nuclear material in the facility over a chosen period and not only a particular overview of the inspection setting. The organization set up for NMC&A by the operators provides more confidence for inspectors. The implementation of an appropriate quality management system impose much more thoughtful and efforts from the operators. However, for French National Safeguards inspectors the implementation of quality management in the regulatory requirements for NMC&A is indeed associated with a regulation more closely followed, a better management of nuclear materials (near-real-time accountancy, identification of materials not being used, etc.), a reduction in dysfunctions at the interfaces of activities and an improved experience feedback. 7